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LIBERI v TAITZ (THIRD CIRCUIT) - Reply by Appellants Defend Our Freedoms Fndtn and Orly Taitz to Response Response - 2-9-11 Transport Room

LIBERI v TAITZ (THIRD CIRCUIT) - Reply by Appellants Defend Our Freedoms Fndtn and Orly Taitz to Response Response - 2-9-11 Transport Room

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Published by Jack Ryan
02/09/2011 Open Document ECF FILER: Reply by Appellants Defend Our Freedoms Fndtn and Orly Taitz to Response Response , filed. Certificate of Service dated 02/08/2011. (OT)
02/09/2011 Open Document ECF FILER: Reply by Appellants Defend Our Freedoms Fndtn and Orly Taitz to Response Response , filed. Certificate of Service dated 02/08/2011. (OT)

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Published by: Jack Ryan on Feb 09, 2011
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02/10/2011

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Liberi v Taitz 02.07.2011 Reply to Response 1
No. 10-3000
 
UNITED STATES COURT OF APPEALSFOR THE THIRD CIRCUIT ____________________LISA LIBERI, et al.,Plaintiffs-Appellees,vs.ORLY TAITZ, et al.,Defendant-Appellants. __________________District Court No. 09_cv_01898_ECREastern District of Pennsylvania
Case: 10-3000 Document: 003110433419 Page: 1 Date Filed: 02/09/2011
 
Liberi v Taitz 02.07.2011 Reply to Response 2
 __________________
APPELLANTS’ REPLY TO APPELLEES’ RESPONSE
 
On 02.01.2011 Appellees filed a response. There is a discrepancy between thenotation on the docket and the caption on the response itself.The docket states:
02/01/2011 ECF FILER: Response filed by Appellees Evelyn Adams, Philip J. Berg, Go ExcelGlobal, Law Ofc of Philip J. Berg, Lisa Liberi and Lisa M. Ostella in Opposition toMotions to recuse Judges Greenaway and Jordan
and for judicial notice
& Motion forAttorney Fees in the amount of $5,000 for time spent in responding to the motions.Certificate of Service dated 02/01/2011. --[Edited 02/02/2011 by AWI] (PJB)
The caption on the pleadings does not include words “Judicial notice”. It is
possible, that it was accidentally omitted, therefore the Appellants reply to theopposition on all accounts.
A.
 
REPLY TO THE OPPOSITION TO JUDICIAL NOTICE
1.
 
First document in the Judicial notice is the transcript of the hearing held on12.20.2011 in front of Judge Robreno. Appellees themselves made thisnotice a part of the proceedings, as they filed a motion for TRO with theThird Circuit Court of Appeals, accusing Appellants of committing multiplecrimes. Third Circuit Court of Appeals referred this matter to the DistrictCourt for hearing, thus this hearing became an integral part of the Appeal.If the transcript and the disposition of the hearing are not reviewed by theThird circuit Court of Appeals, the Third Circuit would be prejudiced againstthe Appellants. The Transcript is absolutely essential for the Appeal. Theessence of the appeal is that the Plaintiffs/Appellees committed fraud byclaiming that the Plaintiff/Appellee Lisa Liberi is the resident of PA, not LisaLiberi, who was convicted in 2008 in CA and who is on probation under thesupervision of the San Bernardino, California Department of Probations.
The court erroneously assumed jurisdiction in this case, based on afraudulent assertion by Liberi and her attorney Berg.
During the
Case: 10-3000 Document: 003110433419 Page: 2 Date Filed: 02/09/2011
 
Liberi v Taitz 02.07.2011 Reply to Response 3
12.20,2010 hearing, during the cross examination of Liberi, conducted bythe Appellant and attorney for the Appellants Taitz, Liberi admitted thatshe is indeed Lisa Liberi, a felon, convicted in 2008 in CA. This admissionhas de facto and de jure decided the Appeal in favor of the Appellants. Suchrequest for judicial notice was not frivolous, but proper, done in good faithand evidence is material for the resolution of the appeal. Additionally,cross examination of Plaintiff/ Appellee Ostella revealed that seriousaccusation mounted against Taitz, specifically allegations that Taitzattempted to kidnap Ostella's children didn't even come from Ostella, butrather were made up by by attorney Berg. this behavior by a licensed PAattorney Philip J Berg is so outrageous and represents such malice and suchegregious misconduct by a licensed attorney, that sua sponte sanctions bythis court against Berg are warranted. this exhibit supports motion forsanctions filed by the Appellants.2.
 
Second document provided as an exhibit with the Motion for theJudicial Notice was the 12.23.2010 order by judge Robreno issued afterthe 12.20.2011 hearing. Judge Robreno stated that there was no basesfor the Motion for the TRO and he did not find any basis for theaccusations made by the Plaintiffs/Appellees. Taitz conducted crossexamination of the Plaintiffs/Appellees Lisa Liberi and Lisa Ostella andexamination of the Plaintiff/Appellee Attorney Berg. Judge Robrenofound all three Plaintiffs/Appellees evasive and not believable: p.9
“Berg’s testimony was also combati
ve, evasive and argumentative andthe court did not find his testimony to be helpful for establishing a
factual record”; p 8 “… Liberi also testified that Taitz tried to hire a “hit
-
man” to harm her and her family and that Taitz encouraged others to
harm her son. On cross examination, Liberi conceded that she was aconvicted felon and that she had no direct evidence linking the websiteto Defendants Belcher or Taitz. Liberi also did not present any credibleevidence to support her claims of murder solicitation and kidnappingattempts. During her testimony Liberi was often combative and evasive,
Case: 10-3000 Document: 003110433419 Page: 3 Date Filed: 02/09/2011

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